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NP—08 · Tax · Finance

International Tax Structuring for Multinational Groups

Managing tax across borders when the rules — and the scrutiny — keep rising.

Audience
Board · CFO · Group Tax Director
Format
5 modules · Hybrid · 8 weeks
Programme Team
International tax lawyers · Former tax authority officials · Group tax directors

The brief.

International tax has moved from a technical back-office function to a board-level question of risk, reputation, and strategy. Pillar Two's global minimum tax, tightening permanent-establishment rules, and public scrutiny mean structures that were efficient a decade ago can now be liabilities.

This programme gives boards and CFOs the framework to oversee international tax as strategy and risk. It covers Pillar Two, permanent-establishment exposure, withholding and treaty optimisation, and the reputational dimension that boards now own.

It is delivered by international tax lawyers, former tax-authority officials, and group tax directors.

Programme modules.

The New International Tax Landscape

BEPS, Pillar Two, and the direction of global tax policy.

Group Structure & Substance

Holding structures, substance requirements, and the end of artificial arrangements.

Permanent Establishment Risk

When activity abroad creates a taxable presence, and how to manage it.

Withholding & Treaty Optimisation

Legitimate treaty use and withholding management across the group.

Tax Reputation & Disclosure

Public country-by-country reporting and the reputational stakes of tax strategy.

What your leadership leaves with.

  • A Pillar Two impact assessment for your group
  • A substance and structure review framework
  • A permanent-establishment risk map
  • A treaty and withholding strategy
  • A tax-reputation and disclosure position
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